Altor guide · 2026-08-30
SDS section 14: what transport information is for
The safety data sheet is already in the booking packet. Section 14 lists a UN number and a proper shipping name. Someone copies both onto the Shipper's Declaration, attaches the SDS, and treats the paper as done. Then the acceptance desk at the cargo terminal parks the freight. The declaration does not match the current list.
That is the SDS pattern. Section 14 was treated as a form. It is a field on a workplace sheet.
What the regulation actually requires
A safety data sheet is a Hazard Communication document. OSHA requires it under 29 CFR 1910.1200. Appendix D of that standard is the 16 section format. Section 14 is Transport information.
Appendix D is where a UN number, proper shipping name, class, and packing group usually sit. That is a GHS starting description. It is not a shipping paper, and it is not a classification decision for this consignment.
The shipping paper sits in a different rulebook. For a US originating shipment, 49 CFR Part 172, Subpart C, is the shipping paper. 49 CFR 172.202 is the basic description: identification number, proper shipping name, hazard class or division, and packing group when one is assigned.
For air, IATA DGR 8.1 requires the Shipper's Declaration for Dangerous Goods. IATA DGR 8.1.6 is the completion standard. Nature and quantity, including packing instruction, package count, and net quantity, go on the form per IATA DGR 8.1.6.9 and 8.1.6.9.2. The operator then runs the acceptance check under IATA DGR 9.1.3. An SDS in the packet does not complete that checklist.
Classification is the offeror's job. 49 CFR 173.22 requires the person who offers the material to class and describe it under parts 172 and 173. ICAO TI Table 3-1, implemented in the IATA DGR List of Dangerous Goods in Section 4.2, is the air list you check against. 49 CFR 172.101 is the US Hazardous Materials Table. The SDS author is not the offeror.
Emergency response information is a third duty. 49 CFR 172.602 requires it to be immediately available for a hazardous materials shipment. An SDS is often kept to meet that duty. Meeting 49 CFR 172.602 does not satisfy 49 CFR 172.202, and it does not satisfy IATA DGR 8.1.
A worked example from the current table. UN 1090 Acetone, Class 3, packing group II. Passenger aircraft: packing instruction 353, 5 L per package. Cargo aircraft: packing instruction 364, 60 L per package. Section 14 may print UN 1090, Acetone, Class 3, packing group II, and stop. That is not a finished air line. The declaration still needs the packing instruction, the net quantity per package, the aircraft type, and the rest of IATA DGR 8.1.6.9.
Packing group is where Section 14 goes stale. UN 1263 Paint, Class 3, packing groups I, II, and III. Packing group II passenger aircraft is packing instruction 353 at 5 L. Packing group III passenger aircraft is packing instruction 355 at 60 L. An SDS written against last year's batch can still say packing group II. This week's drum can test packing group III. Copying Section 14 writes the wrong row before anyone opens the current list.
The mistake people make
Desks copy Section 14 onto the declaration and treat classification as finished.
The UN and the name look familiar, so nobody opens IATA DGR Section 4.2 for this consignment. The packing instruction is blank, or it is a road or sea instruction the SDS author wrote for a different mode. A road description does not become an air description because you copied it onto an IATA form. The aircraft box is ticked later. The quantity is whatever the warehouse packed.
n.o.s. names are the other copy error. Section 14 often prints Flammable liquid, n.o.s. and stops. The chemical that drives the hazard is in Section 3, composition. 49 CFR 172.203(k) still wants that technical name in parentheses on a US paper.
Attaching the SDS is the third skip. The booking has a data sheet, so the desk decides a Shipper's Declaration is extra. IATA DGR 8.1 still requires the form. 49 CFR 172.204 still requires the certification.
Paper versus box is the last one. Section 14, the declaration, and the marks on the fibreboard box are three different documents. Agreement is not automatic. The operator reads the paper and the box together.
A declaration copied from Section 14 is one of the paperwork failures that park freight at the cargo terminal. What to do after a rejection sits at https://altor.consulting/rejected.html.
How to fix it
Treat Section 14 as a hint, not as the form.
Open the SDS for this consignment. Read Section 14 for a UN number and a name to investigate. Read Section 3 when you need composition. Then classify against the current IATA DGR Section 4.2 list, and against 49 CFR 172.101 when the US description governs. Confirm UN number, proper shipping name, class, and packing group for this batch.
Write the Shipper's Declaration from that list. UN 1090 packing group II on a passenger aircraft is packing instruction 353, 5 L per package, not packing instruction 364. UN 1263 packing group III on a passenger aircraft is packing instruction 355, not the packing group II line the SDS still shows. Enter package count and net quantity per IATA DGR 8.1.6.9.2.
Keep the SDS in the pile if it meets 49 CFR 172.602. That is emergency response information. It is not a substitute for the declaration or for the certification in 49 CFR 172.204 and IATA DGR 8.1.6.12.
Walk the packages against the paper in the same order IATA DGR 9.1.3 will. Disagreement between Section 14, the declaration, and the marks is a finding. Fix the line that is wrong. Then sign.
Altor pre-checks completed Dangerous Goods Declarations line by line against the current regulations and returns a written report, with every finding cited, within one business day. You keep the pen. altor.consulting
Catch the rejection before the carrier does
Send your completed declaration before you tender it. A line by line advisory report comes back within 24 hours, every finding cited. $95 flat, one click, and you keep the pen.
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